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"Rights hell" to me would withhold a film from both TV airings and home video.
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I would disagree with this personally; studios have been negotiating TV rights for a much longer time than home video rights, so it is likely that there are plenty of movies for which they still own the rights to show a movie on TV, but did not secure the rights to release the film for sale on video/DVD. If these rights are unobtainable (which, of course, is open to interpretation), I would think that would qualify as "rights hell", at least with regards to a DVD forum.